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Farmers Insurance Exchange v. Tucker11/23/2005
rom FIE . . . ." FIE appeals the denial of an amendment seeking the determination of damages in the declaratory action.
II. STANDARD OF REVIEW
"The denial of a plaintiff's motion to amend a complaint to add another cause of action is governed by an abuse of discretion standard of review." Estate of Becker v. Callahan, 140 Idaho 522, 527, 96 P.3d 623, 628 (2004) (quoting Thomas v. Medical Center Physicians, P.A., 138 Idaho 200, 210, 61 P.3d 557, 567 (2002)).
An "abuse of discretion" standard requires this Court to inquire as to:
(1) whether the trial court correctly perceived the issue as one of discretion; (2) whether the trial court acted within the outer boundaries of its discretion and consistently with the legal standards applicable to the specific choices available to it; and, (3) whether the trial court reached its decision by an exercise of reason.
Sun Valley Shopping Center, Inc. v. Idaho Power Co., 119 Idaho 87, 94, 803 P.2d 993, 1000 (1991).
III. ANALYSIS
A. Did The District Court Abuse Its Discretion In Denying Amendment To Determine the Amount of Damages In The Idaho Declaratory Action?
The Declaratory Judgment Act authorizes courts to declare rights, status, and other legal relations. I.C. § 10-1201. Where the proceeding involves the determination of an issue of fact, such issue may be tried and determined as in other actions. I.C. § 10-1209. In this case, FIE sought an amendment to determine whether it was liable under its umbrella policy and, if so, the extent of its liability for damages. Idaho Rule of Civil Procedure 15(a) instructs that leave to amend shall be freely given when justice so requires. The district court stated that FIE's motion to amend was timely and found that FIE had not filed the motion with "motives of bad faith or dilatory motives", noting that at the time of filing the motion to amend FIE "did not even know that [Tucker and Hoctor] had filed a similar complaint in Montana." The court allowed FIE to file an amended complaint asserting a declaratory claim to determine "whether FIE must pay such damages and to whom it must pay the damages" but it refused amendment "to determine the amount of the damages [Tucker and Hoctor] may seek from FIE in a wrongful death action and/or in a breach of contract action." We must determine whether the district court abused its discretion in denying such amendment.
The district court began its analysis by examining the literal words of the statute. It correctly noted that the literal words of the statute should be given their plain, obvious and rational meaning and that the court does not need to engage in statutory construction if the language is clear and unambiguous. The district court determined that the provisions of the Act are clear and unambiguous and that the court had the ability to "declare a party's rights, status, and other legal relations under [the FIE] insurance contract." The court viewed FIE's request as one primarily seeking to determine an issue of fact, i.e., what amount of damages (if any) FIE needed to pay under its umbrella policy, and stated that a declaratory judgment action was not the proper vehicle to determine such an issue of fact. The district court relied on the following language in Ennis v. Casey, 72 Idaho 181, 238 P.2d 435 (1951):
A statute worded the same as [I.C. § 10-1201] has been enacted by many of the states, also the United States Congress. No authority from any decision of the states, or the United States, has been called to our attention where the statute had been interpreted to include an adjudication of rights and liability which necessitated the determination of wheth
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